Taxation of gains on alienation of property: source State may tax disposals of immovable property and related shares. Immovable property situated in a Contracting State may be taxed in that State. Movable property forming part of a permanent establishment or pertaining to a fixed base in the other State may be taxed in that State, including alienation of the permanent establishment or fixed base. Ships, aircraft and related movable property used in international traffic are taxable only in the enterprise's State of residence. Shares principally consisting of immovable property are taxable in the State where the immovable property is situated; other gains are taxable only in the alienator's State of residence.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of gains on alienation of property: source State may tax disposals of immovable property and related shares.
Immovable property situated in a Contracting State may be taxed in that State. Movable property forming part of a permanent establishment or pertaining to a fixed base in the other State may be taxed in that State, including alienation of the permanent establishment or fixed base. Ships, aircraft and related movable property used in international traffic are taxable only in the enterprise's State of residence. Shares principally consisting of immovable property are taxable in the State where the immovable property is situated; other gains are taxable only in the alienator's State of residence.
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